Compliance and Ethics

In 2009, PG&E began to consolidate the tracking of its compliance efforts in a new Enterprise Compliance Tracking System. As the system matures, it will improve our operating groups' real-time insight into the effectiveness of their compliance efforts and enhance the metrics PG&E currently monitors for its critical compliance areas.

The department also works with a network of Compliance Champions, whose purpose is to identify, develop and promote strategies to establish a consistent, disciplined and sustainable process for achieving excellence in compliance management.

Additionally, personal conduct expectations are communicated through our values, code of conduct, annual compliance and ethics training and other messages to employees. The Employee Code of Conduct emphasizes the company's values, describes our standards of conduct and addresses key regulatory and compliance requirements. We have reviewed and updated the code of conduct every three years since its inception in 1998, and we distributed the most recent edition in April 2010.

Just as we are committed to ethical business conduct and compliance with applicable laws, regulations and policies, we expect the same commitment from our vendors and Board of Directors. We maintain a Contractor, Consultant and Supplier Code of Conduct and a Code of Business Conduct and Ethics for Directors.

In 2009, more than 99 percent of employees completed the annual compliance and ethics training. The training is typically conducted in small groups to stimulate discussion and share experiences. The facilitated training sessions are supported by a video that portrays various compliance or ethical dilemmas employees may face. Our Compliance and Ethics department develops a new training video each year to address current issues and to respond to employees' suggestions.

Finally, we provide opportunities for employees to ask questions and raise concerns. PG&E's Compliance and Ethics Helpline is available to employees, contractors and customers 24 hours a day. The Helpline handled 621 calls in 2009, which is within the best-practice range of 1 to 3 percent of employees calling the Helpline each year. Calls are handled confidentially, and callers can remain anonymous. In 2009, we also began posting on PG&E's internal website confirmed, anonymous employee misconduct and the resulting discipline. This supports a culture where appropriate conduct is expected and reinforces the fact that PG&E takes misconduct seriously and addresses it.